Privacy and Cookie policy

Effective date from September 30th, 2020 to June 30th, 2021

PREAMBULE

This Privacy Policy informs you about how Traefik Labs uses and protects the information you provide to them in the aforementioned situations:

• When you use Traefik Labs’ Website, accessible from the following URL: traefik.io (hereinafter referred to as the "Website");
• When you benefit from a service from Traefik Labs, including when you conclude and execute the license agreement (hereinafter referred to as the “Services”).

Please note that this Privacy Policy may be modified or supplemented at any time by Traefik Labs, in particular to comply with any legal or technological developments. In such a case, its updated date will be clearly identified at the top of this Policy. These modifications apply to the user as soon as they have been informed that the Privacy Policy has been updated or as soon as it is published online.

1. PARTIES

This Privacy Policy is applicable between the Website and Software editor, which is also the services provider, hereinafter referred to as "Traefik Labs", and any person connecting to the Website and/or using the Software, hereinafter referred to as "the User".

2. DEFINITIONS

"Licence Agreement": contractual unit binding the user of the software to Traefik Labs.

"Services": any form of intervention provided out by Traefik Labs.

"Software": all computer programs developed and edited by Traefik Labs.

"User": any person connecting to the Website or benefiting from Services from Traefik Labs, such as using the Software.

"Website": website accessible at the URL traefik.io, as well as sub-sites, mirror sites, portals and URL variations relating thereto.

3. SCOPE

This Privacy Policy is applicable to all Users. By visiting the Website, by using our Software or any of Traefik Labs Services, you agree that your personal data will be handled as described in this Privacy Policy. You acknowledge having read, understood, and fully accepted it.

The User recognizes the probative value of Traefik Labs automatic registration systems, and unless the user can provide evidence of the contrary, he renounces to contest it in case of litigation.

The acceptance of this Privacy Policy implies that the Users enjoy legal capacity required to this end or to be at least 16 years old. If this is not the case, they need to have the permission from a guardian or trustee, their legal representative if they are not 16 years old. Finally, they need to prove that they hold a mandate if they are acting on behalf of a legal entity.

4. PERSONAL DATA COLLECTED AS DATA CONTROLLER

In accordance with the General Data Protection Regulation (GDPR) adopted by the European Parliament on 14 April 2016 and the national legislation in force, Traefik Labs provides you with the following information:

4.1 Identity of the Data Controller

The person responsible for the collection and data processed on the Website is Traefik Labs, French simplified joint stock (société par actions simplifiée), having its registered office at 120 rue Masséna, 69006 Lyon, Commercial Register ID (SIREN): 818103475, [email protected].

4.2 Identity of the Data Protection Officer (DPO)

The Data Protection Officer is Deshoulières Avocats Associés, 121 boulevard de Sébastopol 75002 Paris, +33.1.77.62.82.03, [email protected], www.deshoulieres-avocats.com.

4.3 Data collection by Traefik Labs while you use the Website

This subsection deal with the personal data collected while you use the Website as well as the ways in which these personal data are processed and managed by Traefik Labs.

4.3.1 Data collected

4.3.1.1 Data collected during browsing

When browsing the Website, you consent to Traefik Labs collecting information relating to:

• your use of the Website;
• the content you consult and click on;
• your demographic data;
• the connection data (times, pages viewed, IP address…);
• the geolocation data;
• the website pages you visit before and after using the Website.

4.3.1.2 Data collected when using the contact form

The use of the contact form by the User supposes the collection by Traefik Labs of the following personal data:

• last name;
• first name;
• email address;
• phone number.

Users who do not wish to provide the information required for the use of the contact form will not be able to send a message to Traefik Labs directly from the Website.

4.3.1.3 Data collected when using the newsletter form

In the context of the use of the newsletter form, Traefik Labs may be required to collect and process your email address.

4.3.2 Purposes of the collection of personal data

The data collected during browsing is automatically processed in order to:

• develop, operate, improve, provide and manage the Website;
• contextualize and improve the User's experience;
• send information and contact people, including by e-mail ;
• share Website content with other people or to let people know their consultation or their opinions via the social-network sharing buttons;
• avoid any illicit or illegal activity;
• ensure compliance with the terms and conditions relating to the use of the Website.

The data collected during the use of the contact form is automatically processed in order to:

• provide a detailed answer to the User;
• develop, operate, improve, provide and manage the Website and/or the app;
• send information to and contact the User, including by email and by telephone;
• contextualize and improve the User's experience;
• avoid any illicit or illegal activity;
• ensure compliance with the terms and conditions relating to the use of the Website.

The data collected during the use of the newsletter form is automatically processed in order to:

• send newsletters to the User;
• target advertising content;
• send information to and contact the people.

4.3.3 Legal basis for processing

The data collected during browsing has, as a legal basis, the legitimate interest of Traefik Labs, namely to carry out an analysis of behaviors on the Website, and to obtain an improved safety and functioning of the Website. Some of this data, such as this resulting from the implementation of some cookies, can have as their legal basis the consent of individuals.

The data collected during the use of the contact form has, as a legal basis, the consent of the persons concerned.

The data collected during the use of the newsletter form has, as a legal basis, the consent of the persons concerned.

4.3.4 Data recipients

The collected data can only be viewed by the employees in charge of customer or website management or by Traefik Labs management by the staff in charge of the website management and by the management.

This data, whether in individual or aggregated form, are never made freely viewable by a third person.

4.3.5 Retention period for personal data

The personal data collected during browsing is kept for a reasonable period of time necessary for the proper administration of the Website and for a maximum of 12 months, or until the withdrawal of the consent of the persons concerned.

The personal data collected during the use of the contact form is kept for a reasonable length of time necessary for the proper management of the request of the User and for a maximum of 12 months.

The data collected during the use of the newsletter form are kept until the withdrawal of the consent of the persons concerned.

At the end of each of these periods, Traefik Labs will archive these data and keep them for the time during which Traefik Labs can be held liable.

After the retention period, Traefik Labs undertakes to permanently delete the data of the persons concerned.

4.4 Data collection by Traefik Labs while providing its Services

4.4.1 Data collected

Within the framework of its contractual relations, Traefik Labs may collect and process information from its Users, namely:

• Surnames;
• First names;
• Bank details;
• Telephone number;
• Postal addresses;
• E-mail addresses.

4.4.2 Purposes of the collection of personal data

The data collected during the contractual relationship are subject to automated processing for the following purpose:

• To carry out contractual commitments;
• To contact the Customers ;
• Avoid any illicit or illegal activity;
• To ensure compliance with the general terms and conditions ;
• To initiate legal proceedings ;
• Verify the identity of the Customers.

4.4.3 Legal basis of the processing

The legal basis for the data collected is a contractual relationship.

4.4.4 Recipients of the data

The data collected can only be consulted by Traefik Labs relevant employees within the limits strictly necessary for the execution of the contractual commitments.

This data is also transferred to the partners listed below.

This data, whether in individual or aggregated form, is never made freely viewable by a third party natural person.

4.4.5 Retention period of personal data

The personal data collected is kept for the duration of the contractual relationship, and for the time during which Traefik Labs can be held liable.

Once the retention period has expired, Traefik Labs undertakes to delete the data of the persons concerned permanently without keeping a copy.

4.5 Applicable conditions to your personal data

The following information relates to all personal data collected by Traefik Labs as a data controller.

4.5.1 Security and confidentiality of personal data

Personal data must be kept in secure conditions, within the current technological means, in accordance with the provisions of the General Data Protection Regulation and national legislation in force.

4.5.2 Minimisation of personal data

Traefik Labs may collect and process any data transmitted voluntarily by a the User.

Traefik Labs directs the User as much as possible when they provide useless or superfluous personal data.

Traefik Labs undertakes to only keep and process the data strictly necessary for its activities and will delete any useless data received as soon as possible.

4.5.3 Respect of Rights

You have the following rights regarding your personal data, which can be exercised by writing to us at our postal address or at the following email address: [email protected].

4.5.3.1 Right of information, access, and communication of data

You have the possibility to access the personal data that concerns you.

Due to Traefik Labs obligation of security and confidentiality in the processing of personal data, your request will only be processed if you provide proof of your identity, including a scan of your valid ID (if requested by our dedicated electronic form), or a signed photocopy of your valid ID (if written), both accompanied by the notation "I certify on my honor that this proof of identity is a certified true copy. [City], [Date]", followed by your signature.

To help you, you will find a mail template here prepared by CNIL.

4.5.3.2 Right of rectification, deletion, and right to forgetting data

You have the option to request the rectification, updating, locking, or erasure of personal data that may be inaccurate, erroneous, incomplete, or obsolete.

You can also set general and specific guidelines regarding the handling of your personal data after your death. In this case, the heirs of a deceased person may request to consider the death of their loved one and/or to make the necessary updates.

To help you, you will find a mail template here prepared by CNIL.

4.5.3.3 Right to oppose data processing

You have the possibility to oppose the processing of your personal data.

To this end, you will have to write an email to [email protected]. In this email, you will have to appoint the data you wish to be erased as well as justifying this request, unless it is for commercial prospection reason.

4.5.3.4 Right to data portability

You have the right to receive the personal data you have provided to us in a transferable, open, and readable format.

4.5.3.5 Right to restriction of processing

You have the right to request that the processing of your personal data by Traefik Labs be limited. Thus, your data can only be retained and no longer used by Traefik Labs.

4.5.3.6 Withdrawal of Consent

Your consent is required for the processing of your data by Traefik Labs. However, you can withdraw your consent at any time. This withdrawal will lead to the deletion of your personal data. The services requiring the processing of your data by Traefik Labs will then no longer be accessible.

4.5.3.7 Response times

Traefik Labs undertakes to respond to your request for access, rectification, opposition, or any other request for additional information within a reasonable period of time, which may not exceed 1 month from the receipt of your request.

4.5.3.8 Complaint to the competent authority

If you consider that Traefik Labs does not comply with its obligations regarding your personal information, you may submit a complaint or request to the competent authority. In France, the competent authority is the CNIL, to which you can submit a complaint here.

4.5.4 Transfer of collected data

4.5.4.1 Transfer to partners

Traefik Labs informs you that we use authorized service providers to facilitate the collection and processing of the data you have provided us. These service providers may be located outside the European Union and are provided with the data collected on the Website or while providing our Services.

Traefik Labs has previously ensured the implementation by its providers of adequate safeguards and compliance with strict conditions of confidentiality, use, and protection of data.

Our Website uses social media plug-ins (see the table below). When a plug-in is incorporated in a page of the Website, the social media logo appears in it. When you navigate on a page of the Website containing a plug-in, we transfer your IP address and the URL address of the visited page to the concerned social media.

The User agrees that the data collected will be transmitted by Traefik Labs to its partners and will be processed by these partners as part of third-party services.

Traefik Labs' partners are located in third countries and change regularly. The updated list of these partners can be provided upon request by email to [email protected].

4.5.4.2 Transfer on requisition or court order

The User also agrees that Traefik Labs may communicate the data collected to any person, on the requisition of a state authority or by court order.

4.5.4.3 Transfer as part of a merger or acquisition

If Traefik Labs is involved in a merger, asset sale, financing transaction, liquidation, or bankruptcy or in the event of the acquisition of all or part of its business by another company, the Clients consents that the data collected be transferred by Traefik Labs to this company and that this company carries out the processing of personal data referred to in this privacy policy instead of Traefik Labs.

5. PERSONAL DATA COLLECTED AS SUBCONTRACTOR

As a preliminary, it is essential to precise that Traefik Labs is only intended to act as a data controller regarding its User’s data. Traefik Labs does not have access to the data processed by the Software and integrated by the User into it. Traefik Labs therefore does not act as a data controller or as the subcontractor of the personal data collected and processed by its Users while using the Software.

Traefik Labs undertakes to ensure that its software allows its Users to comply themselves with the law on personal data. However, the choice of hardware, the configuration of the software and the security of the executed cloud services are the responsibility of the Users. Traefik Labs therefore declines any responsibility for any possible violation of the right of personal data in connection with the use of its software.

All information transmitted by the User when editing a ticket, or during a maintenance operation, must imperatively be anonymized.

If, by way of exception and in the absence of any other solution, the User were to communicate to Traefik Labs data concerning its own customers, the following system would apply.

5.1 Description of the subcontracted treatment

Exceptionally, if Traefik Labs is required to process personal data on behalf of the User, this processing is done with express authorization.

The sole purpose of this treatment is to enable Traefik Labs to carry out its maintenance operations.

The amount of personal data processed should be kept to a minimum and will depend on each situation.

This data will only be accessible by the persons in charge of the maintenance operation in question at Traefik Labs.

5.2 Traefik Labs Commitments

5.2.1 Supervision of subcontracting

Traefik Labs undertakes to:

• use the data only for the purposes stated above;
• ensure throughout the duration of the processing that the obligations laid down in the European regulation on data protection are complied with;
• guarantee the confidentiality of the personal data processed within the framework of this Privacy Policy;
• ensure that the persons authorized to process personal data under the Privacy Policy undertake to respect confidentiality or are subject to an appropriate legal obligation of confidentiality and receive the necessary training in the protection of personal data.

These personal data will not be the subject of any subcontracting and Traefik Labs undertakes not to use subsequent subcontractors in the context of this service.

5.2.2 Respect for the rights of individuals

Traefik Labs undertakes to assist the User as soon as its intervention is indispensable to the respect of the rights and exercise requests of the persons concerned.

5.2.3 Notification of personal data breaches

Traefik Labs undertakes to notify the user of any violation of personal data transferred by the user of which it has knowledge.

This notification will be documented and will contain all the elements necessary for the user to comply with its obligations.

5.2.4 Security measures

Traefik Labs is committed to implementing security measures to ensure the confidentiality, integrity, availability and ongoing resilience of processing systems and services.

5.2.5 Data output at the end of the contract

The personal data transferred by the User is subject to final and immediate deletion at the resolution of the ticket or at the end of the maintenance operation.

If, in order to improve its service and monitor the user, Traefik Labs is required to keep the data, the data will be anonymised as far as possible.

5.3 Obligations of the User towards Traefik Labs

5.3.1 Determining the purpose and means of processing

The transfer of the personal data of the User's customers is only intended to allow the completion of a maintenance operation when necessary. The User alone chooses to transfer these data to Traefik Labs, in full knowledge of the means implemented by the latter to carry out the processing.

5.3.2 Treatment supervision

The User undertakes to:

• Provide Traefik Labs with the only personal data necessary in cases where it is not possible to proceed in any other way to put an end to the bug ;
• Certify in writing that these data are transferred as part of a maintenance operation;
• Provide information to the persons concerned by the processing operations at the time of data collection;
• Collect the consent of the data subjects at the time of data collection;
• To carry out the declarations and obtain the authorizations necessary to carry out the processing of the data transmitted to Traefik Labs.
  

5.3.3 Guarantee of personal data

The User guarantees Traefik Labs lawful personal data, in compliance with the General Regulations for the Protection of Personal Data. In this respect, the User undertakes to bear all possible costs and expenses that Traefik Labs may incur as a result of the personal data transmitted, including any legal and procedural costs.

6. POLICY RELATING TO TRACERS/COOKIES

When you first log in to the Traefik Labs website, you are warned by a banner at the bottom of your screen that information about your browsing may be stored in files called "cookies". Our cookie policy allows you to better understand the provisions that we implement in terms of navigation on our website. It informs you in particular about all cookies on our website, their purpose, and gives you the procedure to follow to configure them.

6.1 Use of tracers/cookies

Traefik Labs, as publisher of this web site, may therefore proceed with implantation of a cookie and other tracer on the hard drive of your terminal (computer, tablet, mobile, etc.) to ensure smooth and optimal navigation on our website.

"Cookies" are small text files that allow us to recognize your computer, tablet, or mobile device in order to personalize the services we offer.

To better inform you about the information that cookies identify, you will find below a table listing the different types of cookies that may be used on the Website, their name, purpose, and their retention period.

6.2 Purpose of tracers

With the help of the information contained in the tracers and cookies used, Traefik Labs can analyze the visits and use of the Website and, if necessary, facilitate and improve browsing, carry out prospecting operations, develop commercial statistics, or display targeted ads. These tracers and cookies are also used to monitor, improve, and develop the services and new functionalities offered by Traefik Labs. Finally, Traefik Labs also used the tracers and cookies to better understand the use made by the User of its services.

6.3 Tracers used

Partner	Purpose of the processing	Partner's conditions
Google Analytics	Development of business statistics	https://policies.google.com/technologies/types?hl=en
Youtube	Development of business statistics	https://www.youtube.com/howyoutubeworks/policies/community-guidelines/
LinkedIn	Development of business statistics	https://www.linkedin.com/legal/privacy-policy
Twitter	Development of business statistics	https://twitter.com/en/privacy

6.4 Setting your cookie preferences

When you first log in to the Website, a banner briefly outlining information about cookies and similar technologies will appear at the bottom of your screen.

This banner allows you to choose which cookies you accept or decline to deposit on your terminal. You are deemed to have consented to the deposit of cookies by clicking on the "Got it" icon, either globally or individually. On the other hand, you will be deemed to have refused the deposit of cookies by clicking on the "I refuse" icon. Once again, this choice may be made for all cookies, or only for some of them. If you do not choose, you will be deemed to have refused the deposit of cookies. Your decision will be recorded for 6 months and can be modified at any time.

6.4.1 Cookies exempt from consent

In accordance with the recommendations of the French National Commission for Information Technology and Liberties (CNIL), some cookies are exempt from the prior request for your consent if they are absolutely necessary for the operation of the Website or if their sole purpose is that of enabling or facilitating electronic communication. This includes session ID, verification, load balancing session cookies, as well as cookies for customizing your interface. These cookies are completely subject to this policy to the extent that they are issued and maintained by Traefik Labs.

6.4.2 Cookies requiring the prior collection of your consent

This requirement applies to third-party cookies that are termed "persistent" as long as they remain on your device until deleted or expired.

Since such cookies are issued by third-parties, their use and deposit are subject to their own privacy policies. This cookie family includes audience measurement cookies, advertising cookies, and social network sharing cookies (including Youtube and LinkedIn cookies).

Audience measurement cookies provide statistics about the visits and use of various elements of the Website (such as content/pages you have visited). This data helps improve the ergonomics of the Website.

6.5 Maximum retention period of tracers

Tracers are intended to be kept on the computer station of the Internet for a period of up to 12 months. Personal data is kept in secure conditions, according to the current technological means, in accordance with the provisions of the General Data Protection Regulation and national legislation in force.

6.6 Opposition to the use of tracers

6.6.1 Ability to oppose to the use of tracers

You can accept or refuse the deposit of cookies at any time.

The User can delete or disable the use of tracers whenever they wish by modifying the parameters of their browser. It is possible to consult the Website without tracers. However, some of the site's additional functions may not work if the user has disabled the use of tracers, such as autocomplete forms or browsing indicators.

6.6.2 Settings

For more information on the tools for controlling cookies, you can consult the dedicated page on the CNIL website here.

6.6.2.1 Browser settings

Each Internet browser has its own cookie management settings. The User can configure their browser software so that cookies are rejected, either systematically or depending on their issuer. The User can also configure their browsing software so that their acceptance or refusal of cookies is punctually proposed, before a cookie is likely to be registered on their terminal.

For the management of cookies and User choices, the configuration of each browser is different. It is described in the browser's help menu, which explains how to change cookie preferences:

• For Internet Explorer;
• For Safari;
• For Chrome;
• For Firefox;
• For Opera.

6.6.2.2 Settings by means of add-on modules

The User may also delete or oppose the installation of cookies on his computer by installing an extension on his browser, such as Ghostery, which can be downloaded here.

7. INTELLECTUAL PROPERTY

7.1 Legal protection of the content

The Website and the Software content may be protected by copyright and database rights. Any representation, reproduction, translation, adaptation or transformation, in whole or in part, made illegally and without the consent of Traefik Labs or its successors or assignees is a violation of Books I and III of the Code of Intellectual Property, and may give rise to prosecution for infringement.

7.2 Contractual protection of the content

The User contractually undertakes to Traefik Labs not to use, reproduce, or represent in any way the Website content, whether or not it is protected by intellectual property rights, for a purpose other than their reading by a robot or a browser. This prohibition does not apply to web crawlers which have the sole purpose of scanning the Website content for indexing purposes.

8. FINAL PROVISIONS

8.1 Modifications

This Privacy Policy may be modified at any time by Traefik Labs. The conditions applicable to the User are those in effect when they log on to the Website. Any substantial modification of the present privacy policy will be notified to the User at its first connection following their entry into force. This new privacy policy will then be subject to a new acceptance.

8.2 Entirety

The invalidity of any clause of this agreement will not invalidate the remaining agreement clauses, or the agreement as a whole, which will retain its full force and scope. In such a case, the parties will, as far as possible, replace the invalid provision with a valid provision that corresponds to the spirit and purpose of these terms and conditions.

8.3 Non-waiver

Lack of exercise by Traefik Labs of rights herein acknowledged shall in no case be construed as a waiver of those rights.

8.4 Languages

These terms and conditions are written in English.

8.5 Unfair terms

The stipulations of these terms and conditions apply subject to compliance with the mandatory provisions of the Consumer Code on unfair terms in contracts entered into between a professional and a consumer.

9. LEGAL PROCEEDINGS

9.1 Applicable laws

This Privacy Policy is subject to the application of French law and European regulations, including the European Data Protection Regulation.

9.2 Disputes

Under order No. 2015-1033 of 20 August 2015, all disputes that may arise in the context of the execution of these terms and conditions, and for which an amicable solution has not been found between the parties, must be submitted to Medicys: www.medicys.fr.

9.3 Arbitration

Any dispute concerning or in relation to this agreement must be settled by arbitration in accordance with the FastArbitre regulation of the Digital Institute of Arbitration and Mediation.